Just the Facts 203: FA and F.6.b

1. Just the Facts 203:F&A and F.6.b Ann M. Holmes University of Maryland, College Park

2. � 2008 NCURA 2

3. � 2008 NCURA Allowability and Allocability Considerations: Costs that should �normally� be treated as F&A Costs OMB Guidance on A-21 Revision to section F.6.b. (July 1993) �In developing the departmental administration cost pool, special care should be exercised to ensure that costs incurred for the same purpose in like circumstances are treated consistently as either direct or F&A costs....� 3

4. � 2008 NCURA A-21 Revision - July 1993 �The salaries of administrative and clerical staff should normally be treated as F&A costs. Direct charging of these costs may be appropriate where a major project or activity explicitly budgets for administrative or clerical services and individuals involved can be specifically identified with the project or activity. Items such as office supplies, postage, local telephone costs, and memberships shall normally be treated as F&A costs." [Ref: A-21:F6(b)] 4

5. � 2008 NCURA Implications of F.6.b. Guidance OMB: �Direct charging�.may be appropriate where a major project or activity explicitly budgets for administrative or clerical services� Do we explicitly budget for these costs in the research proposal? Does the the proposal include a written justification (i.e. why the normally indirect costs are necessary for project performance) Is this a �major project� as defined in Exhibit C of A-21? 5

6. � 2008 NCURA Examples of Major Projects Those which require or involve: Extensive data accumulation, analysis, entry... Large amount of travel/meeting arrangements Preparation of manuals, large reports, books... Large, complex programs Geographically inaccessible project locations Conditions including human or animal protocols, multiple-investigator coordination 6 The following examples of major projects are cited in A-21. Note that these examples are NOT exhaustive. They suggest types of projects that are ADMINISTRATIVELY-INTENSIVE. Only the expenses that make the cost �major� may be charged directly to the project. You may not charge all administrative costs to the project just because one expense meets the criteria of a major project or activity. Large, complex programs such as a general clinical research center, program projects, environmental research centers that entail assembling and managing and coordinating teams of investigators from a number of institutions, or large number of PTAs to manage, and many sub-allocations can make the project major.� This is one of the few kinds of projects where it may be appropriate to charge all of the administrative costs directly to the project due to the complexity of the project. Before doing so review Stanford�s Implementation Guidelines for the policy on the Charging of Administrative and Technical Expenses or consult with the Administrative Charging Task Force. Projects that involve extensive data accumulation, analysis and entry, surveying, tabulation cataloging, searching literature and reporting.� �When data entry relates to the project and is part of the scope of work it is a major activity.� The data entry activity may seem administrative, but in this case it is a technical part of the project. The cost associated with this activity can be charged directly to the project, as long as the other criteria are met. Projects which involve extensive travel and meeting arrangements for large numbers of participants. In the case of a travel grant where the purpose of the award is to set up a meeting to discuss the technical aspects of a project all of the administration associated with that project can be charged directly to the project, as long as the other criteria have been met. If only a portion of the project involves extensive travel and/or meeting arrangements then only the administrative expenses associated with making the travel and meeting arrangements constitute a �major activity�. Only the administrative expenses associated with the �major activity� can be charged directly to the project. If a project whose principal focus is the preparation is a large report, manual or website, (excluding routine progress and technical reports) it may be appropriate to charge directly to the project. Projects that are Geographically inaccessible.� For example, if a project conducted on a ship in the Bering Strait requires administrative work, it is reasonable to have an administrator or a copy machine on board the ship to perform administrative tasks.� In that case, it would be appropriate to charge those costs directly, as long as the other criteria have been met. Coordination of project specific database management, individualized graphics or manuscript preparation, multiple project related investigator coordination, human subject or animal protocols to track. Many of these activities seem administrative in nature, but because they are directly associated with the technical scope of the project, it may be appropriate to direct charge the administrative costs associated with this aspect of a project, as long as the other criteria are met.The following examples of major projects are cited in A-21. Note that these examples are NOT exhaustive. They suggest types of projects that are ADMINISTRATIVELY-INTENSIVE. Only the expenses that make the cost �major� may be charged directly to the project. You may not charge all administrative costs to the project just because one expense meets the criteria of a major project or activity. Large, complex programs such as a general clinical research center, program projects, environmental research centers that entail assembling and managing and coordinating teams of investigators from a number of institutions, or large number of PTAs to manage, and many sub-allocations can make the project major.� This is one of the few kinds of projects where it may be appropriate to charge all of the administrative costs directly to the project due to the complexity of the project. Before doing so review Stanford�s Implementation Guidelines for the policy on the Charging of Administrative and Technical Expenses or consult with the Administrative Charging Task Force. Projects that involve extensive data accumulation, analysis and entry, surveying, tabulation cataloging, searching literature and reporting.� �When data entry relates to the project and is part of the scope of work it is a major activity.� The data entry activity may seem administrative, but in this case it is a technical part of the project. The cost associated with this activity can be charged directly to the project, as long as the other criteria are met. Projects which involve extensive travel and meeting arrangements for large numbers of participants. In the case of a travel grant where the purpose of the award is to set up a meeting to discuss the technical aspects of a project all of the administration associated with that project can be charged directly to the project, as long as the other criteria have been met. If only a portion of the project involves extensive travel and/or meeting arrangements then only the administrative expenses associated with making the travel and meeting arrangements constitute a �major activity�. Only the administrative expenses associated with the �major activity� can be charged directly to the project. If a project whose principal focus is the preparation is a large report, manual or website, (excluding routine progress and technical reports) it may be appropriate to charge directly to the project. Projects that are Geographically inaccessible.� For example, if a project conducted on a ship in the Bering Strait requires administrative work, it is reasonable to have an administrator or a copy machine on board the ship to perform administrative tasks.� In that case, it would be appropriate to charge those costs directly, as long as the other criteria have been met. Coordination of project specific database management, individualized graphics or manuscript preparation, multiple project related investigator coordination, human subject or animal protocols to track. Many of these activities seem administrative in nature, but because they are directly associated with the technical scope of the project, it may be appropriate to direct charge the administrative costs associated with this aspect of a project, as long as the other criteria are met.